Colorado Division of Securities

Fraud, excessive fees, failure to maintain records, dishonest/unethical conduct

Stipulation and Consent

Civil and Administrative Penalty(ies)/Fine(s)

$8,500.00

Restitution

$28,000.00

Suspension

Investment Adviser Representative

Fourteen (14) Days

7/15/2018

7/28/2018

Sanctions are ordered against Mitchell Miller and Financial Network Specialists, LLC, the respondents. Respondents are subject to a fourteen (14) day suspension, the respondents may transact business in the best interests of their advisory clients, but the respondents shall not receive any fees or compensation during that period of time. The respondents shall engage a compliance consultant, as approved by the Division of Securities, for a period of two (2) years to review and develop all required policies and procedures. The respondents shall not serve as a trustee or estate representative for any investment advisory client. The respondents are required to pay $36,600 to the Colorado Securities Commissioner. One half was paid at the time the Stipulation was executed and the other half shall be paid within six (6) months from the date of the Consent Order. The $36,500 represents investment advisory fees charged to the client or her trust by the respondents, of which $28,000 constitutes restitution to the ten charity beneficiaries identified in the client's trust and $8,500 constitutes a civil penalty.